Indictment — United States v. Kerwin Aldric Jordan (C.D. Cal.)

Record facts

U.S. District Court for the Central District of California · No. 2:25-cr-00801-SVW · Doc. 1 · 2025-10-01 · Docket on CourtListener

Full text

Case 2:25-cr-00801-SVW

Document 1

Filed 10/01/25

Page 1 of 24 Page ID #:69

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10/1/2025

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UNITED STATES DISTRICT COURT

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FOR THE CENTRAL DISTRICT OF CALIFORNIA

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June 2025 Grand Jury

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UNITED STATES OF AMERICA,

CR 2:25-cr-00801-SVW

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Plaintiff,

I N D I C T M E N T

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v.

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KERWIN ALDRIC JORDAN,

[26 U.S.C. § 7206(2): Aiding and
Assisting in the Preparation of a
False Tax Return; 18 U.S.C.
§ 1343: Wire Fraud; 26 U.S.C.
§ 7301, 28 U.S.C. § 2461(c), 18
U.S.C. § 982: Criminal Forfeiture]

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Defendant.

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The Grand Jury charges:

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COUNTS ONE THROUGH TWENTY-ONE

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[26 U.S.C. § 7206(2)]

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A.

INTRODUCTORY ALLEGATIONS

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At times relevant to this Indictment:

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1.

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Defendant KERWIN ALDRIC JORDAN was a resident of Castaic,

California, and Pebble Beach, California.
2.

Defendant JORDAN owned and operated several businesses,

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including The Jordan Corporation, Jordan and Jordan Financial DBA

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Jordan Tax School, Jordan & Jordan, Jordan and Jordan A Financial

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Conquest, and Euphrates Wealth Asset Management.

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Case 2:25-cr-00801-SVW

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3.

Document 1

Filed 10/01/25

Page 2 of 24 Page ID #:70

Defendant JORDAN was in the business of preparing and

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assisting in the preparation of tax returns for clients for a fee.

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Defendant JORDAN sometimes falsely held himself out to the public as

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a Certified Public Accountant and tax attorney.

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4.

The Internal Revenue Service (IRS) was an agency of the

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U.S. Department of the Treasury responsible for collecting taxes and

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administering the Internal Revenue Code.

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5.

The IRS provided various forms and schedules to be used to

file tax returns.
a.

Form 1040 (U.S. Individual Income Tax Return) was used

to file a taxpayer’s annual income tax return.
b.

Form 1040-X (Amended U.S. Individual Income Tax

Return) was used to make changes to an earlier-filed Form 1040.
c.

Schedule 1 (Additional Income and Adjustments to

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Income) was used to report items that could not be reported on other

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parts of Form 1040. These items could include income or loss from a

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business or profession that the taxpayer had engaged in as a sole

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proprietor.

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d.

Schedule A (Itemized Deductions) was used to report

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itemized deductions. These items could include medical and dental

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expenses, home mortgage interest, gifts to charity, and unreimbursed

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employee expenses.

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e.

Schedule C (Profit or Loss from Business (Sole

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Proprietorship)) was used to report income or loss from a business or

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profession that the taxpayer had engaged in as a sole proprietor.

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Case 2:25-cr-00801-SVW

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B.

Filed 10/01/25

Page 3 of 24 Page ID #:71

FALSE TAX RETURNS
6.

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Document 1

On or about the dates set forth below, in Los Angeles

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County, within the Central District of California, and elsewhere,

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defendant JORDAN willfully aided and assisted in, and procured,

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counseled, and advised the preparation and presentation to the IRS,

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of U.S. Individual Income Tax Returns, Forms 1040, and Amended U.S.

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Individual Income Tax Returns, Forms 1040-X, for the years and in the

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names of the taxpayers set forth below, which returns were false and

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fraudulent as to a material matter, in that the returns reported

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false and fictitious business gross receipts and business expenses,

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as reported on the attached Schedules C and line 3 of the attached

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Schedules 1, which were used fraudulently to offset the taxpayers’

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income and fraudulently reduce the amount of reported tax owed. As

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defendant JORDAN then knew, the claimed business losses were false

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and, as a result of these fraudulently claimed business losses,

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defendant JORDAN did not report the taxes his clients actually owed

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and, in many cases, defendant JORDAN claimed refunds from the IRS on

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behalf of his clients to which his clients were not entitled.

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Case 2:25-cr-00801-SVW

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2
3

COUNT FILING
DATE
1

2/18/2020

Document 1

Filed 10/01/25

Page 4 of 24 Page ID #:72

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

N.N.

2019
Form
1040

a. Sch. C (N.N.), line 31,
net profit or (loss):
($27,355)

4
5

b. Sch. 1, line 3, business
income or (loss): ($27,355)

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7

c. Form 1040, line 11b,
taxable income: $53,474

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9

d. Form 1040, line 21a,
refund: $7,836

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3/17/2020

A.S. & S.S.

2019
Form
1040

a. Sch. C (A.S.), line 31,
net profit or (loss):
($82,439)
b. Sch. C (S.S.), line 31,
net profit or (loss):
($10,044)

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c. Sch. C (S.S.), line 31,
net profit or (loss):
($33,279)

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d. Sch. 1, line 3, business
income or (loss):
($125,762)

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e. Form 1040, line 11b,
taxable income: $205,883

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f. Form 1040, line 21a,
refund: $16,116

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Case 2:25-cr-00801-SVW

1
2
3

COUNT FILING
DATE
3

3/27/2020

Document 1

Filed 10/01/25

Page 5 of 24 Page ID #:73

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

A.M. & S.N.

2019
Form
1040

a. Sch. C (A.S.M.), line
31, net profit or (loss):
($81,850)

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5

b. Sch. C (S.V.N.), line
31, net profit or (loss):
($137,169)

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c. Sch. 1, line 3, business
income or (loss):
($219,019)

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d. Form 1040, line 11b,
taxable income: $606,963

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e. Form 1040, line 21a,
refund: $105

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4/3/2020

H.G. & L.G.

2019
Form
1040

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a. Sch. C (L.G.), line 31,
net profit or (loss):
($158,498)
b. Sch. 1, line 3, business
income or (loss):
($158,498)

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c. Form 1040, line 11b,
taxable income: $83,406

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d. Form 1040, line 21a,
refund: $38,739

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Case 2:25-cr-00801-SVW

1
2
3

COUNT FILING
DATE
5

4/6/2020

Document 1

Filed 10/01/25

Page 6 of 24 Page ID #:74

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

M.N.

2019
Form
1040

a. Sch. C (M.N.), line 31,
net profit or (loss):
($139,161)

4
5

b. Sch. 1, line 3, business
income or (loss):
($139,161)

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c. Form 1040, line 11b,
taxable income: $312,409

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d. Form 1040, line 21a,
refund: $6,150

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13

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5/19/2020

A.K.D. &
N.D.

2019
Form
1040

a. Sch. C (A.K.D.), line
31, net profit or (loss):
($49,257)

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b. Sch. C (N.D.), line 31,
net profit or (loss):
($18,997)

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c. Sch. 1, line 3, business
income or (loss): ($68,254)

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d. Form 1040, line 11b,
taxable income: $161,063

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e. Form 1040, line 21a,
refund: $5,137

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Case 2:25-cr-00801-SVW

1
2
3

COUNT FILING
DATE
7

2/9/2021

Document 1

Filed 10/01/25

Page 7 of 24 Page ID #:75

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

N.N.

2020
Form
1040

a. Sch. C (N.N.), line 31,
net profit or (loss):
($58,365)

4
5

b. Sch. 1, line 3, business
income or (loss): ($58,365)

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7

c. Form 1040, line 15,
taxable income: $116,651

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d. Form 1040, line 35a,
refund: $12,736

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3/8/2021

A.M. & S.N.

2020
Form
1040

a. Sch. C (A.S.M.), line
31, net profit or (loss):
($70,490)
b. Sch. C (S.V.N.), line
31, net profit or (loss):
($78,567)

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c. Sch. 1, line 3, business
income or (loss):
($149,057)

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d. Form 1040, line 15,
taxable income: $398,093

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e. Form 1040, line 35a,
refund: $17,488

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Case 2:25-cr-00801-SVW

1
2
3

COUNT FILING
DATE
9

3/11/2021

Document 1

Filed 10/01/25

Page 8 of 24 Page ID #:76

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

A.S. & S.S.

2020
Form
1040

a. Sch. C (A.S.), line 31,
net profit or (loss):
($88,453)

4
5

b. Sch. C (S.S.), line 31,
net profit or (loss):
($55,462)

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8

c. Sch. C (S.S.), line 31,
net profit or (loss):
$31,042

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10

d. Sch. 1, line 3, business
income or (loss):
($112,873)

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e. Form 1040, line 15,
taxable income: $152,338

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f. Form 1040, line 35a,
refund: $27,887

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19

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3/11/2021

H.G. & L.G.

2020
Form
1040

a. Sch. C (L.G.), line 31,
net profit or (loss):
($18,747)
b. Sch. 1, line 3, business
income or (loss): ($18,747)

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c. Form 1040, line 15,
taxable income: $15,814

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d. Form 1040, line 35a,
refund: $15,374

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Case 2:25-cr-00801-SVW

1
2
3

COUNT FILING
DATE
11

4/12/2021

Document 1

Filed 10/01/25

Page 9 of 24 Page ID #:77

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

S.T. & S.W.

2020
Form
1040

a. Sch. C (S.T.), line 31,
net profit or (loss):
($41,246)

4
5

b. Sch. C (S.W.), line 31,
net profit or (loss):
($11,765)

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8

c. Sch. 1, line 3, business
income or (loss): ($53,011)

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d. Form 1040, line 15,
taxable income: $106,356

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e. Form 1040, line 35a,
refund: $520

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15

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4/30/2021

M.N.

2020
Form
1040

a. Sch. C (M.N.), line 31,
net profit or (loss):
($473,027)

16
b. Sch. 1, line 3, business
income or (loss):
($473,027)

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c. Form 1040, line 15,
taxable income: $574,386

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d. Form 1040, line 35a,
refund: $31,471

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Case 2:25-cr-00801-SVW

1
2
3

COUNT FILING
DATE
13

5/24/2021

Document 1

Filed 10/01/25

Page 10 of 24 Page ID #:78

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

S.T. & S.W.

2020
Form
1040-X

a. Sch. C (S.T.), line 31,
net profit or (loss):
($41,246)

4
5

a. Sch. C (S.W.), line 31,
net profit or (loss):
($11,765)

6
7
8

b. Sch. 1, line 3, business
income or (loss): ($53,011)

9
10

c. Form 1040-X, line 5,
taxable income: $106,356

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12

d. Form 1040-X, line 22,
refund: $500

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14
15

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6/9/2021

S.T. & S.W.

2019
Form
1040

a. Sch. C (S.T.), line 31,
net profit or (loss):
($31,760)

16
b. Sch. 1, line 3, business
income or (loss): ($31,760)

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18

c. Form 1040, line 11b,
taxable income: $69,228

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d. Form 1040, line 21a,
refund: $9,541

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Case 2:25-cr-00801-SVW

1
2
3

COUNT FILING
DATE
15

2/17/2022

Document 1

Filed 10/01/25

Page 11 of 24 Page ID #:79

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

S.T. & S.W.

2021
Form
1040

a. Sch. C (S.T.), line 31,
net profit or (loss):
($45,639)

4
5

b. Sch. C (S.W.), line 31,
net profit or (loss):
($37,126)

6
7
8

c. Sch. 1, line 3, business
income or (loss): ($82,765)

9
10

d. Form 1040, line 15,
taxable income: $42,647

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12

e. Form 1040, line 35a,
refund: $21,664

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14
15

16

2/22/2022

N.N.

2021
Form
1040

a. Sch. C (N.N.), line 31,
net profit or (loss):
($176,764)

16
b. Sch. 1, line 3, business
income or (loss):
($176,764)

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18
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c. Form 1040, line 15,
taxable income: $188,891

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d. Form 1040, line 35a,
refund: $17,432

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26
27
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Case 2:25-cr-00801-SVW

1
2
3

COUNT FILING
DATE
17

3/10/2022

Document 1

Filed 10/01/25

Page 12 of 24 Page ID #:80

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

B.T.

2021
Form
1040

a. Sch. C (B.T.), line 31,
net profit or (loss):
($169,744)

4
5

b. Sch. 1, line 3, business
income or (loss):
($169,744)

6
7
8

c. Form 1040, line 15,
taxable income: $327,726

9
10

d. Form 1040, line 35a,
refund: $30,088

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12
13

18

3/11/2022

A.M. & S.N.

2021
Form
1040

a. Sch. C (A.S.M.), line
31, net profit or (loss):
($92,185)

14
b. Sch. C (S.V.N.), line
31, net profit or (loss):
($93,107)

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c. Sch. 1, line 3, business
income or (loss):
($185,292)

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d. Form 1040, line 15,
taxable income: $436,936

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e. Form 1040, line 35a,
refund: $20,319

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Case 2:25-cr-00801-SVW

1
2
3
4

COUNT FILING
DATE
19

3/16/2022

Document 1

Filed 10/01/25

Page 13 of 24 Page ID #:81

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

A.S. & S.S.

2021
Form
1040

a. Sch. C (A.S.), line 31,
net profit or (loss):
($99,674)

5
b. Sch. C (S.S.), line 31,
net profit or (loss):
($84,597)

6
7
8

c. Sch. C (S.S.), line 31,
net profit or (loss):
$17,540

9
10

d. Sch. 1, line 3, business
income or (loss):
($166,731)

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12
13

e. Form 1040, line 15,
taxable income: $117,702

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15

f. Form 1040, line 35a,
refund: $38,196

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Case 2:25-cr-00801-SVW

1
2
3
4

COUNT FILING
DATE
20

4/2/2022

Document 1

Filed 10/01/25

Page 14 of 24 Page ID #:82

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

A.K.D. &
N.D.

2021
Form
1040

a. Sch. C (A.K.D.), line
31, net profit or (loss):
($386,795)

5
b. Sch. C (N.D.), line 31,
net profit or (loss):
($382,973)

6
7
8

c. Sch. C (A.K.D.), line
31, net profit or (loss):
($272,601)

9
10

d. Sch. 1, line 3, business
income or (loss):
($1,042,369)

11
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e. Form 1040, line 15,
taxable income: $960,178

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15

f. Form 1040, line 35a,
refund: $24,866

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Case 2:25-cr-00801-SVW

1
2
3
4

COUNT FILING
DATE
21

4/5/2022

Document 1

Filed 10/01/25

Page 15 of 24 Page ID #:83

TAXPAYER(S)

YEAR &
FORM

FALSE ITEMS

M.C. &
H.J.L.

2021
Form
1040

a. Sch. C (M.C.), line 31,
net profit or (loss):
($143,286)

5
b. Sch. C (M.C.),
line 31, net profit or
(loss): ($104,031)

6
7
8

c. Sch. C (H.J.L.), line
31, net profit or (loss):
($105,987)

9
10

d. Sch. 1, line 3, business
income or (loss):
($353,304)

11
12
13

e. Form 1040, line 15,
taxable income: $854,891

14
15

f. Form 1040, line 35a,
refund: $65,241

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Case 2:25-cr-00801-SVW

Document 1

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Page 16 of 24 Page ID #:84

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COUNTS TWENTY-TWO THROUGH TWENTY-SIX

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[18 U.S.C. § 1343]

3

A.

INTRODUCTORY ALLEGATIONS

4

At times relevant to this Indictment:

5

7.

6
7

The Grand Jury realleges paragraphs 1 through 3 of this

Indictment here.
8.

Defendant JORDAN was signatory to and maintained control of

8

Wells Fargo Bank account #0253, which he had opened in the name of

9

Kerwin Jordan & Jordan Financial.

10

9.

Defendant JORDAN was signatory to and maintained control of

11

JPMorgan Chase bank account #9595, which he had opened in the name of

12

Euphrates Wealth Asset Management.

13

The Paycheck Protection Program

14

10.

The Coronavirus Aid, Relief, and Economic Security

15

(“CARES”) Act was a federal law enacted in or about March 2020 that

16

was designed to provide emergency financial assistance to Americans

17

suffering economic harm as a result of the COVID-19 pandemic. One

18

form of assistance provided by the CARES Act was the authorization of

19

United States taxpayer funds in forgivable loans to small businesses

20

for job retention and certain other expenses, through a program

21

referred to as the Paycheck Protection Program (“PPP”).

22

11.

In order to obtain a PPP loan, a qualifying business was

23

required to submit a PPP loan application signed by an authorized

24

representative of the business. The PPP loan application required the

25

small business (through its authorized representative) to acknowledge

26

the program rules and make certain affirmative certifications in

27

order to be eligible to obtain the PPP loan. One such certification

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required the applicant to affirm that “[t]he [PPP loan] funds w[ould]
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Case 2:25-cr-00801-SVW

Document 1

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Page 17 of 24 Page ID #:85

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be used to retain workers and maintain payroll or make mortgage

2

interest payments, lease payments, and utility payments.” The

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applicant (through its authorized representative) was also required

4

to acknowledge that “I understand that if the funds are used for

5

unauthorized purposes, the federal government may pursue criminal

6

fraud charges.” In the PPP loan application, the applicant was

7

required to state, among other things, its (a) average monthly

8

payroll expenses and (b) number of employees. These figures were used

9

to calculate the amount of money the small business was eligible to

10

receive under the PPP. In addition, the applicant was required to

11

provide documentation showing its payroll expenses.

12

12.

A business’s PPP loan application was received and

13

processed, in the first instance, by a participating financial

14

institution. If a PPP loan application was approved, the

15

participating financial institution would fund the PPP loan using its

16

own monies.

17

13.

PPP loan proceeds were required to be used by the business

18

on certain permissible expenses, namely, payroll costs, interest on

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mortgages, rent, and utilities. The PPP allowed the interest and

20

principal on the PPP loan to be forgiven entirely if the business

21

spent the loan proceeds on these expenses within a designated period

22

of time and used at least a minimum amount of the PPP loan proceeds

23

towards payroll expenses.

24

The Economic Injury Disaster Loan Program

25

14.

The Economic Injury Disaster Loan (“EIDL”) Program was a

26

U.S. Small Business Administration (“SBA”) program that provided low-

27

interest financing to small businesses, renters, and homeowners in

28

regions affected by declared disasters.
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Case 2:25-cr-00801-SVW

1

15.

Document 1

Filed 10/01/25

Page 18 of 24 Page ID #:86

The CARES Act authorized the SBA to provide EIDL loans of

2

up to $2 million to eligible small businesses experiencing

3

substantial financial disruption due to the COVID-19 pandemic.

4

16.

To obtain an EIDL loan, a qualifying business was required

5

to submit an application to the SBA and provide information about the

6

business’s operations, such as the number of employees, gross

7

revenues for the twelve-month period preceding the disaster, and cost

8

of goods sold in the twelve-month period preceding the disaster. In

9

the case of EIDL loans for COVID-19 relief, the twelve-month period

10

was the twelve-month period from January 31, 2019, to January 31,

11

2020. The applicant was also required to certify that all of the

12

information in the application was true and correct to the best of

13

the applicant’s knowledge.

14

17.

EIDL loan applications were submitted directly to the SBA

15

and processed by the agency with support from a government

16

contractor. The amount of the loan, if the application was approved,

17

was determined based, in part, on the information provided by the

18

applicant about employment, revenue, and cost of goods sold, as

19

described in paragraph 16 above. Any funds issued under an EIDL loan

20

were issued directly by the SBA.

21

18.

EIDL loan funds could be used for payroll expenses, sick

22

leave, production costs, and business obligations, such as debts,

23

rent, and mortgage payments. If the applicant also obtained a loan

24

under the PPP, the EIDL loan funds could not be used for the same

25

purpose as the PPP loan funds.

26

B.

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THE SCHEME TO DEFRAUD
19.

Beginning by at least April 10, 2020, and continuing until

at least January 7, 2023, in Los Angeles County, within the Central
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District of California, and elsewhere, defendant JORDAN, together

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with others known and unknown to the Grand Jury, knowingly and with

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intent to defraud, devised, participated in, and executed a scheme to

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defraud the SBA and financial institutions, and to obtain money and

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property by means of materially false and fraudulent pretenses,

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representations, and promises.

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8

20.

The fraudulent scheme operated, in substance, as follows:
a.

Defendant JORDAN made, and caused to be made, false

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statements to the SBA and financial institutions in connection with

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fraudulent applications for PPP and EIDL loans, including false

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representations regarding the number of employees to whom the

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applicant-company had paid wages and false certifications that the

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loans would be used for permissible business purposes.

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b.

Defendant JORDAN electronically submitted, and caused

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to be submitted, a false document to the SBA and a financial

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institution in support of a fraudulent PPP loan application, namely,

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a false and fictitious tax document.

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c.

Defendant JORDAN directed the PPP and EIDL loan

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proceeds to be deposited into bank accounts that defendant JORDAN

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controlled.

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d.

Defendant JORDAN used the fraudulently obtained PPP

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and EIDL loan proceeds for his own personal benefit, including for

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expenses prohibited under the requirements of the PPP and EIDL

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programs, such as using PPP and EIDL proceeds to purchase jewelry.

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e.

Instead of paying back the PPP loans, defendant JORDAN

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filed applications for forgiveness of the loans based on false

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statements that the PPP proceeds had been spent on payroll costs.

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Case 2:25-cr-00801-SVW

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C.

Document 1

Filed 10/01/25

Page 20 of 24 Page ID #:88

USE OF INTERSTATE WIRES
21.

2

On or about the dates set forth below, in Los Angeles

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County, within the Central District of California, and elsewhere, for

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the purpose of executing the above-described scheme to defraud,

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defendant JORDAN transmitted and caused the transmission of the

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following items by means of wire communication in interstate

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commerce:

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COUNT DATE
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4/16/2020 $41,667 in PPP loan proceeds transferred from
WebBank to Wells Fargo account #0253 by means of
an interstate wire

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6/24/2020 Application for EIDL loan submitted to the SBA in
the name of “Euphrates Wealth Asset Management”
by means of an interstate wire

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8/11/2020 $39,300 in EIDL loan proceeds transferred from
SBA to JPMorgan Chase account #9595 by means of
an interstate wire

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2/4/2021

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2/25/2021 $53,802 in second draw PPP loan proceeds
transferred from WebBank to Wells Fargo Bank
account #0253 by means of an interstate wire

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ITEM

$93,198 in PPP loan proceeds transferred from
Cross River Bank to Wells Fargo Bank account
#0253 by means of an interstate wire

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Case 2:25-cr-00801-SVW

Document 1

Filed 10/01/25

Page 21 of 24 Page ID #:89

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FORFEITURE ALLEGATION ONE

2

[26 U.S.C. § 7301 and 28 U.S.C. § 2461(c)]

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1.

Pursuant to Rule 32.2(a) of the Federal Rules of Criminal

4

Procedure, notice is hereby given that the United States of America

5

will seek forfeiture as part of any sentence, pursuant to Title 26,

6

United States Code, 7301, and Title 28, United States Code, Section

7

2461(c), in the event of the defendant’s conviction of the offenses

8

set forth in any of Counts One through Twenty-One of this Indictment.

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2.

The defendant, if so convicted, shall forfeit to the United

States of America the following:

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(a) Any property sold or removed by the defendant in fraud

12

of the internal revenue laws, or with design to avoid payment of such

13

tax, or which was removed, deposited, or concealed, with intent to

14

defraud the United States of such tax or any part thereof;

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(b) All property manufactured into property of a kind

16

subject to tax for the purpose of selling such taxable property in

17

fraud of the internal revenue laws, or with design to evade the

18

payment of such tax;

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(c) All property whatsoever, in the place or building, or

20

any yard or enclosure, where the property described in subsection (a)

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or (b) is found, or which is intended to be used in the making of

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property described in subsection (a), with intent to defraud the

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United States of tax or any part thereof, on the property described

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in subsection (a);

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(d) All property used as a container for, or which shall
have contained, property described in subsection (a) or (b);

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(e) Any property (including aircraft, vehicles, vessels, or

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draft animals) used to transport or for the deposit or concealment of
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property described in subsection (a) or (b), or any property used to

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transport or for the deposit or concealment of property which is

3

intended to be used in the making or packaging of property described

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in subsection (a); and

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(f)

To the extent that such property is not available for

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forfeiture, a sum of money equal to the total value of the property

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described in this paragraph.

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3.

Pursuant to Title 21, United States Code, Section 853(p),

9

as incorporated by Title 28, United States Code, Section 2461(c), the

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defendant, if so convicted, shall forfeit substitute property, up to

11

the total value of the property described in the preceding paragraph

12

if, as the result of any act or omission of the defendant, the

13

property described in the preceding paragraph, or any portion thereof

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(a) cannot be located upon the exercise of due diligence; (b) has

15

been transferred, sold to or deposited with a third party; (c) has

16

been placed beyond the jurisdiction of the court; (d) has been

17

substantially diminished in value; or (e) has been commingled with

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other property that cannot be divided without difficulty.

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Case 2:25-cr-00801-SVW

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Page 23 of 24 Page ID #:91

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FORFEITURE ALLEGATION TWO

2

[18 U.S.C. § 982]

3

1.

Pursuant to Rule 32.2(a) of the Federal Rules of Criminal

4

Procedure, notice is hereby given that the United States of America

5

will seek forfeiture as part of any sentence, pursuant to Title 18,

6

United States Code, Section 982(a)(2), in the event of the

7

defendant’s conviction of the offenses set forth in any of Counts

8

Twenty-Two through Twenty-Six of this Indictment.

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10

2.

The defendant, if so convicted, shall forfeit to the United

States of America the following:

11

(a) All right, title and interest in any and all property,

12

real or personal, constituting, or derived from, any proceeds

13

obtained, directly or indirectly, as a result of the offense; and

14

(b) To the extent such property is not available for

15

forfeiture, a sum of money equal to the total value of the property

16

described in subparagraph (a).

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///

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///

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///

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Case 2:25-cr-00801-SVW

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3.

Document 1

Filed 10/01/25

Page 24 of 24 Page ID #:92

Pursuant to Title 21, United States Code, Section 853(p),

2

as incorporated by Title 18, United States Code, Section 982(b), the

3

defendant, if so convicted, shall forfeit substitute property, up to

4

the total value of the property described in the preceding paragraph

5

if, as the result of any act or omission of the defendant, the

6

property described in the preceding paragraph, or any portion

7

thereof: (a) cannot be located upon the exercise of due diligence;

8

(b) has been transferred, sold to or deposited with a third party;

9

(c) has been placed beyond the jurisdiction of the court; (d) has

10

been substantially diminished in value; or (e) has been commingled

11

with other property that cannot be divided without difficulty.

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A TRUE BILL

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_/S/_____________________________
Foreperson
BILAL A. ESSAYLI
Acting United States Attorney

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JOSEPH T. McNALLY
Assistant United States Attorney
Acting Chief, Criminal Division
ALEXANDER P. ROBBINS
Assistant United States Attorney
Acting Chief, Criminal Appeals Section
MATTHEW R. HOFFMAN
Trial Attorney, Tax Division
United States Department of Justice
RANEE A. KATZENSTEIN
Assistant United States Attorney
Acting Deputy Chief, Criminal Appeals Section

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